Filters Cannot Correct all Flaws

By
DANA M. ROWLAND

MASTER OF SCIENCEGEOGRAPHIC INFORMATION SYSTEMS TECHNOLOGYFINAL PROJECTTHE UNIVERSITY OF ARIZONA
2024

ACKNOWLEDGMENTS
I would like to thank my instructors for their hard work and long hours. Their
dedication to the success of their students reminded me that I have success inside mewith each passing day. Additionally, their patience empowered me to overcome the
obstacles that I have faced along the way. They have reminded me that the journey isthe destination.

1

TABLE OF CONTENTS
page
ACKNOWLEDGMENTS .................................................................................................. 1
LIST OF TABLES ............................................................................................................ 4
LIST OF FIGURES .......................................................................................................... 5
LIST OF ABBREVIATIONS ............................................................................................. 6
ABSTRACT ..................................................................................................................... 9
INTRODUCTION ........................................................................................................... 10
METHODS .................................................................................................................... 28
Study Area .............................................................................................................. 28
Methodology ........................................................................................................... 31
Main Data Resources Utilized ................................................................................. 31
RESULTS...................................................................................................................... 32
Gelogy and Groundwater ........................................................................................ 32
Fairchild AFB Airframe History ................................................................................ 34
Prior Fairchild AFB Enviromental Contamination Investigations ............................. 35
The 2017 Contamination in Airway Heights, WA .................................................... 41
Hydrocarbons ................................................................................................... 45
PFAS ................................................................................................................ 46
Craig Roal Landfill ............................................................................................ 48
Military Fire-Fighting Training with AFFF .......................................................... 48
Aircraft Crashes of Airway Heights, WA ........................................................... 51
Wildland Fires................................................................................................... 56
Agricultural Chemicals ...................................................................................... 56
Biosolid Fertilizer........................................................................................ 56
Pestisides and their Packaging .................................................................. 59
APPENDIX A ................................................................................................................. 63
U.S. Patent 3,258,423............................................................................................. 64
APPENDIX B ................................................................................................................. 69
Hazourdous Geology .............................................................................................. 70
APPENDIX C ................................................................................................................ 73
C.1 – E.I. Du Pont De Nemous & Co., 18 February 1970 ....................................... 742

C.2 – Chemical Concentrates Corp., 15 June 1970 ................................................ 75
C.3 – 3M, 08 September 1981 ................................................................................ 77
C.4 – 3M, 14 December 1981 ................................................................................. 80
APPENDIX D ................................................................................................................ 81
D.1 – PFC ............................................................................................................... 82
D.2 – Teflon ............................................................................................................ 83
D.3 – Face Masks ................................................................................................... 85
LIST OF REFERENCES ............................................................................................... 82

3

LIST OF TABLES
Table

page

1

Coating products or materials coated with PFAS ................................................. 6

2

Building and construction industry PFAS uses ................................................... 18

3

Types of items when PFAS is used for cleaning................................................. 18

4

Cosmetics and personal care products .............................................................. 18

5

Electronics .......................................................................................................... 20

6

Explosives, propellants, and ammunition uses ................................................... 21

7

Metal plating products ........................................................................................ 21

8

Packaging, paper, and cardboard....................................................................... 22

9

Plastics, resins, and rubber ................................................................................ 23

10

Textiles ............................................................................................................... 25

11

Transportation .................................................................................................... 25

12

Medical components and parts ........................................................................... 26

4

LIST OF FIGURES
Figurepage

Figure 1. Molecular Structures of Intermediate Amido-Polymethylene. ........................ 12
Figure 2. Fluorocarbon Compounds ............................................................................ 14
Figure 3. Reference map of Spokane County, WA with Boundary Lines.. ..................... 9
Figure 4. Reference map of Spokane County, WA with Geology.. ................................. 95

LIST OF ABBREVIATIONS
1,1-DCE

1,1-Dichloroethylene

ACC

Air Combat Command

AFB

Air Force Base

AFFF

Aqueous Film Forming Foam

AFCEC

U.S. Air Force Civil Engineer Center

AMC

Air Mobility Command

ARW

Air Refueling Wing

ATSDR

Agency for Toxic Substances and Disease Registry

CBI

Confidential Business Information

CDC

Centers for Disease Control and Prevention

CRL

Craig Road Landfill

DAH

Department of Health

DOD

Department of Defense

EA

exposure assessment

EPA

U.S. Environmental Protection Agency

FFA

Federal Facility Agreement (an interagency agreement)

FDA

Federal Department of Agriculture

FT-1

Fire Training Area [Fairchild AFB]

GIS

Geographical Information Systems

HRS

Hazard Ranking System

II/SHA

Initial Investigation/Site Hazard Assessment

IRP

Installation Restoration Program

IS-1

Building 1034 French Drain System [Fairchild AFB]

6

MCL

maximum contaminant levels

MTCA

Model Toxics Control Act

NDA

Northwest Disposal Area

NFA

No Further Action

NPL

National Priorities List

OU

Operable Unit (1 & 2)

OWS

oil water separator

P-1

Priority-1 sites

PAH

polycyclic aromatic hydrocarbons

PET

positron emission tomography

PFAS

Per- and Polyfluoroalkyl Substances

PFBS

Perfluorobutane sulfonic acid

PFC

Perfluorinated chemicals

PFCA

Perfluoroalkyl carboxylic acid

PFHpA

Perfluoroheptanoic acid

PFHxS

Perfluorohexane sulfonic acid

PFNA

Perfluorononanoic acid

PFOA

Perfluorooctanoic acid

PFOS

Perfluorooctane sulfonic acidppb

parts per billion

ppt

parts per trillion

PTFE

Polytetrafluoroethylene

psipounds per square inch

PWS

public water systems

RI

Remedial Investigation

7

ROD

Record of Decision

SAC

Strategic Air Command

SDA

Southwest Disposal Area

SDWA

Safe Drinking Water Act

SME

subject matter experts

SW-1

Old Base Landfill northeast of Taxiway No.7 [Fairchild AFB]

TCE

Trichloroethylene

TRCA

Time-Critical Removal Action

TRI

Toxics Release Inventory

USMR

Unregulated Contaminant Monitoring Rule

USAF

United States Air Force

USGS

U.S. Geological Survey

VOCvolatile organic compound

WANG

Washington Air National Guard

WDOE

Washington Department of Ecology

WSDH

Washington State Department of HealthWW-1

Wastewater Lagoons [Fairchild AFB]

WWTP

Waste Water Treatment Plant

8

Abstract
A severe concern of contamination from Per- and Polyfluoroalkyl Substances(PFAS) surfaced in May of 2017. The local water sources of Airway Heights,
Washington showed to have PFAS compounds that were uncommon. The state’s smallcity sits east of Fairchild Air Force Base (AFB). In 1993 Fairchild AFB was put on the
National Priorities List (NPL) for water contamination in conjunction with anunderground leak of JP-4 fuel. Similarly to water testing twenty-four years prior,
Fairchild AFB underwent well testing on base and off-base in the Spring of 2017. The
goal of this project was to assess research data, primary sources, current clean-up
plans and findings to contextualize if the claims that the water contamination was solely
due to Fairchild AFB's firefighters' aqueous film-forming foam (AFFF) finding its way into
the potable water sources of Airway Heights, WA stands resolute today. Could it bepossible that one or multiple sources of PFAS compounds are to bear some
responsibility? Areas of interest were wildland fires, landfills, and historical locations ofaircraft crashes within the boundaries an area deemed ‘West Plains’ in Spokane
County, Washington, and the possibility that pesticides utilized on local farmlands could
have contained hazardous PFAS compounds. Methods used to compile empirical data
were first-hand conversations with subject matter experts (SME) and department leadsof WA environmental agencies, primary source reports, peer reviewed articles, andmedia articles. Current results show possibilities lying with historical usage of AFFF
from historical events of the area and a local landfill that was used for all wastes,
including hazardous waste.
Keywords: AFFF; PFAS; Fairchild AFB; Water Contamination; Airway Heights, WA

9Introduction
Fairchild AFB was initially established in 1942 as a U.S. Army repair depot
named Spokane Army Air Depot or referred to as “Galena Air Depot” by locals, due toits proximity to the Galena Railway Station (92nd Air Refueling Wing, Public Affairs,2013). Since 1942, varying quantities of hazardous wastes from fuel management,
industrial and aircraft operations, and fire training activities have been generated anddisposed of onsite. It is said that Spokane businesses and private citizens of Airway
Heights donated more than $125,000 to the War Department to purchase 1,400 acresof local land for the development of the initial strategic air facility. After opening, from1942 to 1949, the base served as a repair depot providing maintenance and repair toaircrafts in order to return them to the mission in the Pacific Theater. The summer of1946 saw the base’s reassignment to the 15th Air Force and transfer to the Strategic Air
Command (SAC). A year later herald the arrival of the time’s most advanced bomber
along with the 92nd and 98th Bombing Groups. During the years 1949 to 1958, the Old
Base Landfill located northeast of Taxiway No. 7 was the Army Depot’s main disposal
area. It received industrial waste that included plating sludge, solvents, and lubricatingoils. During this time, in November 1950, the base that had just been renamed in 1948
to ‘Spokane AFB’, saw the installation’s current naming to ‘Fairchild Air Force Base’. To
commemorate a native Washingtonian and ranking officer who had recently passed, it
was decided to dedicate the growing location to Air Force Vice Chief of Staff, General
Muir S. Fairchild. General Fairchild was from Bellingham, Washington and originallyentered the U.S. military via the Washington National Guard (ARMY) in June 1916. Hedied while on duty in the Pentagon in March 1950. Being so integral to various aircraft10

missions over what has now been eighty-two years, Fairchild AFB has seen its fairshare of innovation, invention, and intrinsic re-evaluation surrounding the realm of
mechanics. One such life altering category is in the means of safety. Specifically, fire
safety (Matrix Design Group, Inc., 2009).
Methods have been devised for the application of fire-fighting foams by spraying
or injecting a coherent foam blanket on the surface of a burning fuel. Patent 3,258,423
related to novel compositions covering a low flash point flammable liquid to prevent
ignition or reignition of the same when exposed to a nearby flame or source of ignition.
The spray-gun invented was to be manufactured and used by the Government of theUnited States of America for governmental purposes without the payment of any
royalties. Fire-fighting foams work to extinguish fires in two ways: they block the
feedback of radiant energy to a fuel surface and prevent further release of flammablevapor after flames have been suppressed. The United States Patent 3,258,423(Patented June 28, 1966) Method of Extinguishing Liquid Hydrocarbon Fires describes
AFFF as constituting essentially air-water emulsions that display a substantial capability
to distribute a thin layer of water in an active foam. This means that once distributed
over a fire area, the film dispenses a useful water content which does not drain rapidly
from a hydrocarbon surface. To test the foam for its patent, three tests were conducted
to demonstrate the foam’s abilities. Fuels for the tests were motor oil in Test 1 andgasoline for both Test 2 and 3. Preferred fluorocarbons utilized for testing comprised of
the following quaternary nitrogen compounds which have an intermediate amido
polyethylene linkage in their molecular structure (Figure 1).

11

Figure 1
Molecular Structures of Intermediate Amido-Polymethylene Linkage of Fluorocarbon
Compounds utilized in Patent 3,258,423 (Sec.3)
Test 1 utilized motor-oil as its fuel and compound (A) to make a 1 percent
aqueous solution that was expanded by air to a volume of about 10. The foam
prevented ignition by an open flame and when ignition was finally affected only a small
amount of vapor was present to permit a brief flash across the surface. Agitation with aprobe disclosed that it was difficult to break open the barrier to get a sustained flame.
When exposed surfaces of fuel were finally obtained, the exposed fuel would not takefire until repeated agitation in one area and then it was quickly extinguished.
Test 2 added a small amount of fluorescent material (sodium fluorescein) to thesolution in Test 1 to test on gasoline. The green glow of the foam was soon observed
spreading in all directions. As the foam began to disintegrate, the green glow grew
outward.
Test 3 was a field scale test involving a 14-foot diameter gasoline fire to further
test the foams film barrier, its mobility, and self-sealing ability. A foam roughly
containing 0.5 percent of compound (D) was blown with air over the entire burning
surface to give a density of about 0.06 gallon of solution per square foot of fuel surface
until the fire was extinguished. After a lapse of at least one minute, a torch was brought
over the opening left by the lid. The surface could not be ignited even with agitation.

12

Gaps also occurred in the foam blanket and the foam was subject to considerable
movement by the wind.
Test 1 indicated the presence of a useful film that forms a surface barrier capableof suppressing fuel vaporization. Test 2, after the green foam had seemingly
disintegrated, the green coloration had spread over an area many times larger than theinitial foam sprayed site. Test 3 emphasized that the vulnerable surfaces could not be
ignited even with agitation. This test resulted in that the surface film formed held
together by resealing itself throughout the period in which the gasoline surface wasbeing agitated.
As for the breakdown of these foams, it is stated to involve evaporation from thesurface and drainage of liquid from the bubble wall and interstices. It is from thisdescription that the term “light water” was said to be coined as a descriptive term for
AFFF for its ability to foam from very dilute solutions containing a small concentration of
the perfluoro-carbon foaming materials. This allowed for the acceptance of perfluorocarbon foams simply require water deposition containing a soluble compound thatcompletely disintegrates. The patent further promotes the foam’s water content in a waythat can be perceived as misleading. Potential misdirection derives from playing to the
foam’s water content, preventing the notion that the foam is not harmful to theenvironment as it will disappear, disintegrate, and/or evaporate. A non-organic does notdissolve into nature becoming a part of its surroundings. Chemicals seep into or leachinto their surroundings causing contamination and ill-willed affects.
Patent 3,258,423 concludes that perfluorocarbon foams have been found to bevery advantageous in combating fuel fires with their unique ability to combat

13hydrocarbon fuel with highly flammable vapors. A method of extinguishing a liquidhydrocarbon fire which comprises covering the burning area of the liquid hydrocarbon
with an aqueous foam having a non-combustible gas phase and an aqueous liquid
phase which contains a solution from about 0.1 to 10 percent by weight on a surfaceactive fluorocarbon compound selected from the group below (Figure 2).

andFigure 2
Fluorocarbon Compounds(Tuve & Jablonski, 1966; Sec. 7)
No environmental impact variables were identified to either bolster the pros or identify
cons from the testing of the foam. However, it provides the illusion that AFFF foams do
not have an impact on the environment outside of a fire, specifically water, due to thecomplete disintegration of these foams results essentially in water deposition containing
a soluble compound (Tuve & Jablonski, 1966). To view the patent in full, see Appendix
A.
A broad understanding of these chemicals allows for a broad range of uses toinclude daily utilized sources. PFAS compounds have been used to make products that
resist heat, oil, stains, grease, and water by including a fluoropolymer coating (Agency
for Toxic Substances and Disease Registry, 2020). Fluoropolymer coatings have been
included in textiles, furniture, adhesives, food packaging, heat-resistant non-stick14

cooking surfaces, pesticides, insulation of electrical wire, and Class B fire-fighting foam,
AFFF.
Applications that PFAS have been used range over 25 broad industries.
Historical and current usage of per- and polyfluoroalkyl substances PFAS): A literature
review explains and consolidates information on PFAS from 307 sources into 22 pages(Gaines, 2022). Reviewed industries are briefly described in the following section of thispaper.
Industries:
Surface Treatments and High-performance surfactants in products that must flow evenly
Coatings, wax, paint, varnish, and inks: PFAS used in various coating products to
reduce surface tension for substrate wetting, penetration, leveling, spreading, dispersing
agents; improving gloss, uniform surface coverage, and antistatic and antifoulingproperties (Table 1). For dyes and inks, PFAS are used to combat pigment flotation
issues, improve flow, and eliminate snowflaking.
Fire-Fighting foam: A broad range of groups, including the military (army, air force,and navy), civilian airports, municipal fire departments, and merchant ship crews can beusers of AFFF, which they use to extinguish hydrocarbon fires at airports, train yards,
ships, oil refineries, oil platforms, and other locations.
Oil and gas: PFAS may be used as surfactants to enhance recovery in oil or gas
recovery wells. PFAS polymers may be used in oil well elastomers and due to theirstability at high temperatures and pressures, liquid fluorinated compounds may be usedin well drilling, completion, or workover operations.

15

Table 1
Coating products or materials coatedwith PFAS(Gaines, 2022; p. 357)

16

Pesticides and fertilizers: PFAS have been used as an active and inert (or inactive)
pesticide ingredient. Active ingredients are those that kill the intended pest, while
inactive ingredients help the active ingredient by helping it get to or stay on the surface
being protected.
Adhesives: Used in solvent- and water-based adhesives to ensure complete contact
between joining surfaces and retard foaming. PFAS is used with urea‐formaldehydeadhesive resins for wood particleboard bonding to improve the cold‐water swelling andinternal bond strength. These improvements occur by reducing the resin's interfacial
tension and improving substrate wetting.
Building and construction: PFAS reduces cement shrinkage and may be used tostabilize aqueous foam used to allow for flowable concrete mixtures (Table 2).
Ceramics and nanostructures synthesis: PFAS were used in supercritical caron
dioxide fluid to synthesize ceramics including titanium dioxide and silver chloride.
Cleaning products: PFAS is used to lower surface tension and thus to improvewetting, enhance penetration, and improve rinse-off as well as improve antifogging
characteristics in many products for both industrial and household uses (Table 3).
Cosmetics and personal care: PFAS is used as emulsifiers, lubricants, or oleophobic
agents in cosmetics. There are also findings in hair-conditioning formulations andcreams to promote lubricity, facilitate wet combing, and render hair oleophobic (Table
4). Several patents include PFAS in the make-up of hand sanitizer. A 1958 patent for
dental floss states the use of aliphatic perfluoroalkyl carboxylic acid (PFCA) in its
preparation.

17

Table 2
Building and construction industry PFAS uses
(Gaines, 2022; p.355)
Table 3
Types of items when PFAS is used for cleaning(Gaines, 2022; p.356)

Table 4
Cosmetics and personal careproducts(Gaines, 2022; p.358)
18

Dry cleaning: There are patents that state the use of hydrofluoroethers with other
PFAS being used in lieu of tetrachlorethene or other solvents under the premise thatthey are less aggressive on fabrics and assist in their drying faster.
Electronics: Cured epoxy resins are removed from integrated circuit modules withsolutions containing small amounts of PFAS. Additional uses are in, low-foaming
noncorrosive wetting agents in solders for electrical parts and cleaning of electricalcomponents (Table 5). Perfluorooctanoic acid (PFOA) is notably used to makefluoropolymers in cable and wire insulation for computer networks due to its dielectric,
low flammability, chemical and heat resistance.
Semiconductors (engineering coatings used in semiconductor manufacture): PFAS
are used in the semiconductor industry to reduce surface tension and reflectivity of
etching solutions to facilitate precise photolithography.
Etching: PFAS is used as wetting agents in etch baths for materials like glass, plastics,
fused silica, and aluminum.
Explosives, propellants, and ammunition: Fluorocarbons have been used as
pyrotechnic oxidizer (Table 6). The pyrotechnic material has been a combination offluoropolymer and a metal like magnesium or aluminum for the visual flare composition.
Metal plating and finishing: PFAS were previously used for decorative chrome plating
as a surfactant wetting agent, and mist-suppressing agent in chrome plating (Table 7).
This industry has seen generations of PFAS derivatives.

19

Table 5
Electronics(Gaines, 2022; p. 358)

20

Table 6
Explosives, propellants, andammunition uses
(Gaines, 2022; p.361)

Table 7
Metal plating products(Gaines, 2022; p. 364)
21

Photography and lithography: Several PFAS have been seen in manufacturing film,
paper, and plates. They have been used as both dirt rejecters and friction control agents
as well as to reduce surface tension and static
electricity. PFAS can be used in medical
diagnostics, including imaging as MRI, ultrasound,
positron emission tomography (PET), multi-modal
contrast agents as well as medical devices like
implantable material, devices, parts, andcomponents.
Packaging, paper, and cardboard: PFAS provide
water and oil resistance to paper products for bothfood and nonfood use. PFAS food contact uses
primarily cover their waterproofing and grease‐proofing properties in paper and paperboard
products (Table 8). Perfluorooctyl sulfonamido
ethanol‐based phosphates were the first
substances used to provide grease repellence tofood contact papers, followed by fluorotelomer thiol‐
based phosphates and polymers' use.
Plastics, resins, and rubber: Numerous PFAS

Table 8
Packaging, paper, and cardboard(Gaines, 2022; 365)

have been used as processing aids, raw material, or manufacturing intermediate influoropolymer production. Fluoropolymers have hundreds of uses in consumer andindustrial products, such as plastics, textiles, medical industry, and in critical industrial

22

applications. PFAS are used as mold‐release agents for thermoplastics, polypropylene,
epoxy resins, and polyurethane elastomer foam molding, in formulations for anti‐
blocking agents for vulcanized and unvulcanized rubbers, and in silicone rubber
sealants. Use for coating cookware for nonstick properties (Table 9).
Table 9
Plastics, resins, and rubber(Gaines, 2022; p. 367)

23

Recycling and material recovery: PFAS is used in the solvent extraction processes
which can recover metals, in particular rare earth metals, from metal waste. In tests,
some heavy metals were recovered at 100 percent efficiency after two extractions
steps, and the solvent could be reused. With high extraction percentages, supercriticalcarbon dioxide with PFAS surfactants have been investigated to remove radioactive
cesium from contaminated soil and sand. There has been less success resulting fromtesting the removal process on contaminated concrete.
Textiles: Since 1951, the use of PFAS for its dispersion products to coat fabrics to repel
oil, water, and stains. Various companies have made fluorinated chemicals for use on
textiles to include DuPont (Zonyl, Captone, and Foraperle) and 3M (Scotchgard).
Extractable PFCAs were found in pretreated carpets, treated apparel, gloves, home andoutdoor textiles, leather, and awning textiles. Fluoropolymers can also be spun into
fibers and used to make luggage, sailcloth, and fabric for fire suppression (Table 10).
High molecular mass polytetrafluoroethylene (PTFE) can be fibrillated to make highly
porous fabrics, which are widely used in outdoor wear and camping accessories.
Textiles made from fiberglass coated with or saturated with PFAS can also be used forhigh temperature or corrosive industrial environments.
Refrigerants: Polytetrafluoroethylene perhaps mostly referred to as refrigerants. Many
have physiochemical properties that make them ideal for use in air conditioning,refrigeration, etc.
Transportation: PFAS seen in car manufacturers, airplane manufacturers, shipping
industry, aerospace manufacturing has a lot to do with the manufacturing of the parts
and waste (Table 11).

24

Table 10
Textiles(Gaines, 2022; p. 369)

Table 11
Transportation(Gaines, 2022; p. 369)

25

Medical components and parts: Potentially, the first considered PFAS medical use
was with Clark and Gollan's 1966 experiment involving animals breathing a PFC
emulsion and similarly as a substitute blood due to their oxygen‐carrying ability and as apossible decompression illness treatment (Table 12).

Table 12
Medical components and parts(Gaines, 2022; p. 363)
26

Mining: PFAS may have been used as surfactants to enhance metal recovery fromores in copper and gold mines. They can be used in the ore flotation process toseparate metal salts from soil and in electrowinning of metals, including in nitrogenflotation to recover uranium.
Scientific general uses: Various PFAS have been used in general laboratory work.
Trifluoroacetic acid – ion-pairing agent of choice for reversed‐phase high‐performanceliquid chromatography of peptides and proteins.
 Derivatizing agents - gas chromatography or laboratory analytical reagents
 PTFE - scientific equipment like chromatography needles, syringe filters,
bottles, caps, and closure linings
In 2017, there was a mass contamination crisis in the City of Airway Heights,
Spokane County Washington. Blame for the contamination of their water supply, toinclude local wells, causing the turn-off of their water at the source was accepted by the
local military base. PFAS chemicals, at extreme amounts, were identified in water wells
near and bordering the west fence line of the installation. Locations of said wells gave
way to the swift placement of blame upon the shoulders of the United States military.
Other means of possible contributors are also local. Local landfills (one having been
specifically used for hazardous material), pesticides utilized on near agriculture land,
and historical fires both wildland fires and aircraft crashes. The research of this paper isrooted in the theory that there is usually not one singular point of blame for mass
environmental contamination. It is the goal of this project to see if there are other local
sources or a more probable source that caused the PFAS water contamination of
Airway Heights, WA in 2017.

27

Methods
Study Area
The State of Washington is home to an area referred to as West Plains near its
eastern border with Idaho. West Plains lies west of the City of Spokane yet within
Spokane County limits (Figure 3). It is relatively flat outside of its slight slope from thesouthwest to the northwest, towards the Spokane River. With such a terrain paired withshallow topsoil, a high-water table, and shallow bedrock, flooding is made possible.
Geographically located in the Columbia Basin Province, the area is engulfed withvarious grassland and shrub-steppe vegetation which grades into ponderosa pine forest
and onto the Deep Creek Watershed with the water flow being generally to the east andnortheast. Local variations of flow may result from local changes in bedrock topography(Parsons Engineering Science, Inc., 1996; Bay West, 2018).
This topography is shared with Airway Heights and Fairchild AFB (Appendix B).
Fairchild AFB is 4,300 acres roughly 12 miles West of the City of Spokane.
Approximately 700 acres in the northeast corner and southern portion of the installation
are primarily unimproved areas, open grass fields, and stands of ponderosa pine, alongwith areas of mixed native and nonnative grasses, weeds, and shrubs (Figure 4). Most
surface drainage at the installation is directed into ponds, wetlands, and swales locatedwithin the boundaries of the installation (EA, Inc., 1996; Bay West, 2018).

28

Figure 3
Reference map of Spokane
County, WA with boundarylines of Spokane County,
WA & county municipalities
and their labels.
Produced in ArcGIS Pro byDana Rowland, 2023.

Figure 4
Reference map of
Spokane County, WAwith bodies of water& hazardous geology
layers on top of World
Imagery.
Produced in ArcGIS
Pro by Dana
Rowland, 2023.

29

Fairchild AFB has as a shallow subsurface geological make-up of Tertiary
volcanics and Quaternary sediments consisting of eolian-era, glacial, fluvial, lacustrine,and catastrophic flood deposits. Flood waters from the glacial-era Missoula Lakescoured the basalt bedrock of this region of the Columbia Plateau. During early flood
water recession, course sediments were deposited followed by finer sediments during
the later stages. Relatively little surface water exists within the installation boundary due
to a series of collection ponds located on the installation and the high permeability on
the surface soils (Weston, 2010; Bay West, 2018). Anthropogenic deposits, either as
reworked alluvium (Figure 4) for base development purposes or non-native fill material,
are present at shallow depths within the developed portion of the installation.
Unconsolidated deposits generally follow the slope of the underlying basalt bedrock(Parsons Engineering Science, Inc., 1996; Bay West, 2018).
Bedrock in the vicinity of Fairchild AFB is seemingly a collection of Tertiary
basalts of the Columbia River Group, specifically of the Wanapum Formation. Saidbasalt flows are interbedded with Latah Formation sedimentary clay and silt. Basalt flow
found below the base appears to be divided into upper and lower flow sequence by aninterbed of the Latah Formation silt unit (Parsons Engineering Science, Inc., 1996; Bay
West, 2018).
Data analysis was completed through layers of documented reports – both
civilian and U.S. government as well as reviewing ongoing investigation results in thearea of West Plains, WA. Layering of historical data of hazardous waste management
and accidents involving potential PFAS laden materials with the known use of AFFF andtheir proximity to residential areas to aid in contextualizing timeframes from possible

30

contributing factors with current contamination. The reasoning these methods werechosen was due to there not being any other root cause(s) to the water contamination of
PFAS chemical strands being documented outside of hydrocarbon firefighting foam
used by the military; no documentation scientifically ruling-out other possible avenues
either utilizing the same firefighting foam or even other sources that include PFAS
compounds in their chemical make-up.
Methodology
By utilizing qualitative methodology, secondary data was analyzed. Informationand data regarding the wells tested in Airway Heights, WA, near and on Fairchild AFB
was gathered from news publications, primary sources crafted by the Department of
Defense and scientific findings of third-party entities. Findings consisted of empiricalwater, soil, and human blood and/or urine samples compiled from various test sessions
before and after the announcement of the city’s drinking water contamination.
Main Data Resources Utilized
Main sources of physical sampling results were obtained from a few sources.
The Installation Restoration Program Phase II – Confirmation/Qualification Presurvey
from November 1985, Remedial Investigation Report: Craig Road Landfill (CRL) from
April 1992, Installation Restoration Program (IRP) Record of Decision (ROD) On-BasePriority One Operable Units report from June 1993, Final Site Inspection Report
Fairchild Air Force Base, Washington from January 2019, and Technical Memorandum
PFAS Trend Analysis Report Fairchild Air Force Base from August 2020.
Digital publication searches were conducted via public domain search engines
Google Chrome and Microsoft Edge. Search words and phrases used were PFAS,

31

AFFF, Airway Heights, WA water contamination, fire-fighting foam, Fairchild AFB watercontamination, WA wildfires, wildland fire suppressants, and wildland retardants.
Geographical Information System (GIS) datasets searched for were Airway Heights, WA
boundary, Fairchild AFB boundary, Airway Heights’ tested wells, Fairchild AFB tested
wells, Craig Road Landfill location, aircraft crash(es) location(s), Fairchild AFB firefighter trainings utilizing AFFF data (i.e. number of onsite trainings with dates, amount of
AFFF used, means of disposal, etc.), and local well testing prior to and after trainings.
Databases searched include U.S. Environmental Protection Agency (EPA), U.S.
Geological Survey (USGS), Washington State Department of Health (DAH), National
Library of Medicine: National Center for Biotechnology Information, U.S. Air Force Civil
Engineer Center (AFCEC) Administrative Record, Quick Search ASSIST, and the
Bureau of Aircraft Accidents Archives. Without any documentation outside of local news
articles and various public affairs postings Fairchild AFB’s website of current actions
post the publicized 2017 contamination, this project began with scant amount ofevidence. Though no GIS datasets were located for wildland fires in Spokane Co., WAor for the wells tested on and around Fairchild AFB, the ill advisement of AFFF and
PFAS companies and the entities like the U.S. DOD that employed them, was found tobe evident.
Results
Geology and Groundwater
The West Plains is a result of volcanic activity where lava poured throughEastern Washington, cooling and hardening to form the area’s foundation.(Villa &Breda, 2023). This is evident from its two layers of basalt from different periods. To

32varying degrees, silt, pebbles, boulders and other aggregates were deposited by
cataclysmic floods during the last ice age, resulting in a fairly level surface covering apatchwork of underground aquifers, drainage channels, and differing bedrock levels.
(McCain, 2013).
Where Fairchild AFB is located, the geographical make-up is that of two basalt
formations overlain by alluvial soil. These layers of basalt are referred to as Basalt A
flow and Basalt B flow and separated by low-permeability clay with a thickness range ofeight to ten feet. The clay has limited space between particles and thus is a confining
layer, restricting the flow of groundwater (Utah Geological Survey, n.d.).
The alluvial soil is a mixture of clays with silts interlaced with sandy silts, sandy
clays, and sandy gravels with a thickness range from one foot 46 feet. The top of Basalt
A is fractured and weathered with its thickness varying across the base - approximately
165 feet to 193 feet. Its center area is fine grain basalt with infrequent fractures and low
permeability.
Groundwater in the alluvial and Basalt A aquifers generally flows from west toeast across Fairchild, typically eight to 20 feet below the ground surface. The water flow
within Basalt A is predominantly within the upper and lower portions of the formation
where the degree of interconnected fractures is highest. Vertical groundwater
movement through Basalt A is typically slow due to the tightness of fractures within thecenter of the basalt formation (US EPA, 1993). Today, groundwater here in the West
Plains near Spokane flows northeast and supplies hundreds of residential wells withdrinking water (Landess, 2023).

33

Groundwater in the vicinity of Fairchild AFB is encountered between
approximately 8 and 20 feet below the ground surface and is present in both theunconsolidated overburden material and the underlying basalt bedrock. Groundwater inthe overburden and shallow bedrock is generally unconfined, with some locally semiconfined areas. Water level data collected at Fairchild AFB in 2015 indicates a relatively
shallow gradient exists across the site. It demonstrates the shallow aquifer’s (alluvium)
average horizontal gradient ranges from about 0.0035 to 0.0041 feet/foot. The average
horizontal gradient in the basalt aquifer ranges from about 0.0028 to 0.0045 feet/foot,also indicating a shallow gradient (Bay West, 2016).
Fairchild AFB Airframe History
For five years, from 1942 to 1946, Airway Heights, WA was home to an ARMY
Air Depot repairing aircrafts. It was not until 1947 that this location had their own
aircrafts. When the 92nd and 98th Bomb Groups arrived that summer, they brought withthem their B-29 Superfortress birds. 1951 came with the wing’s first B-36 Peacemakerbomber and all before 1959, Fairchild AFB saw the airframe transition again to the B-52
Stratofortress and KC-135 Stratotanker. Together, Fairchild AFB’s KC-135s and B-52s
provided refueling and bomber support for countless operations. Operations inSoutheast Asia during the mid-1960s and Desert Storm and Desert Shield in 1990 and1991. Then in 1994, following their command changing to the Air Combat Command(ACC) triggering the movement of the bombers to another base and the re-naming of
the wing from 92nd Bomb Wing to the 92nd Air Refueling Wing (92 ARW), the 92nd
changed again. They became part of the Air Mobility Command (AMC) (Matrix DesignGroup, Inc., 2009).

34

Since then, the 92 ARW has been involved in virtually every contingency mission
worldwide. They have been a force extender in the midst of combat operations,humanitarian relief missions. Fairchild AFB has become home to not only the activeduty personnel of the 92 ARW, but also the 336th Training Group, Joint Personnel
Recovery Agency, and the 141st Air Refueling Wing - Washington Air National Guard(WANG) (Matrix Design Group, Inc., 2009).
Prior Fairchild AFB Environmental Contamination Investigations
Environmental investigations of past hazardous waste disposal practices andsites were initiated at Fairchild AFB in 1984 as part of the United States Air Force(USAF) the Installation Restoration Program (IRP). In 1985, the first report summarizing
IRP investigations at Fairchild AFB was published. 1993 saw the publications of the
EPA’s Superfund Record of Decision: Fairchild Air Force Base (4 Waste Areas) OU1 in
February and another ROD for OU2 sites, Superfund Record of Decision: Fairchild Air
Force Base 4 Areas (Operable Unit 2), WA Second Remedial Action in July. The
Record of Decision (ROD) for both the identified OU1 location, the Craig Road Landfill(CRL) and OU2 locations on the Fairchild AFB, Spokane, Washington were signed by
the United States Department of the Air Force, The United States Environmental
Protection Agency (EPA), and the state of Washington Department of Ecology(Ecology). The February ROD addressed the source contamination at CRL and onsite
and offsite ground water, as OU1. July’s ROD addressed soil and ground watercontamination at five separate Priority 1 (P1) locations as OU2.
Preliminary findings in the July report identified the P1 sites for additional
investigations, which were to continue through the remediation of the site. It documents

35

that since conception in 1942, varying quantities of hazardous wastes from fuelmanagement, industrial and aircraft operations, and fire training activities have been
generated and disposed of onsite. Analyzed areas on Fairchild AFB consisted of five
separate P1 OUs sited in the report are as follows: SW-1 (Old Base Landfill northeast of Taxiway No.7)
 IS-1 (Building 1034 French Drain System) OU1 (Flightline Sites PS-2, PS-6, PS-8)
 FT-1 (Fire Training Area) WW-1 (Wastewater Lagoons)Ultimately, key contaminates that were sifted-out were volatile organic compounds(VOCs) (benzene, trichloroethylene (TCE), toluene, xylenes), other organics polycyclicaromatic hydrocarbons (PAHs), and metals (chromium, lead). From about 1949 to 1958,
the SW-1 landfill was the main disposal area for the base and received industrial waste
including plating sludge, solvents, and lubricating oils. The Building 1034 French drain
system was constructed to dispose of wastewater from an inside sink and the roof
runoff of the building. Like many fabrications, other uses were not only possible with alack of filtering and ease of access, but likely probable. It is believed that hazardous
materials, including waste solvents, mineral spirits, cleaning compounds, and acidsolutions were washed into the drain system. The Air Force completed a non-timecritical removal action to remove and treat offsite contaminated sediment and waterfrom the manholes of the French drain system in conjunction with rerouting drainage
from the sink and roof and sealing the manholes with water-tight gaskets.
Additional IRP investigations occurred in phases.

36 IRP Phase I Record Search: 1984-1985
 IRP Phase II Confirmation/Qualification, Stage 1: 1986-1988
 IRP Phase III Confirmation/Qualification, Stage 1: 1988-1990
Since 1986, environmental samples (i.e. soil, sediment, surface water, andgroundwater samples) have been collected at Fairchild’s P1 sites over 11 separate
rounds of sampling. Rounds 1 through 7 were conducted from 1986 to 1990 and arereferred to in the Remedial Investigation (RI) Report and ROD as historical data.
Sampling rounds 8 through 11 were conducted from 1991 to 1992. As the ROD for the
IRP investigation was published in 1993, the results for the latter were referred to as
current data. Past disposal practices revealed in the Department of Defense’s
Installation Restoration Program (IRP) provided insight into onsite groundwater and soil
contamination.
The flightline operable unit (OU1) is comprised of three separate sites referred to as PS2, PS-8, and PS-6.
PS-2 included the tank at refueling/defueling Pit 18. Between 1984 and 1985,
approximately 5,120 gallons of JP-4 fuel leaked/spilled from a cracked flange on the.
4,000 gallons are thought to have been recovered where 1,000 gallons was notaccounted for; believed to have entered the storm sewer and soil. During flightline
foundation drilling at the location and during Stage 1 of the IRP Phase II in 1989,
petroleum products appeared in the groundwater, giving validity to this belief.
PS-6 is located adjacent to the north side of Buildings 1011 and 1013, and west of
Taxiway No.3. In 1986, due to a malfunction of an underground defueling tank’s shut-off

37

valve, approximately 3,550 gallons of JP-4 fuel leaked. Recovered fuel is said to havebeen utilized in following fire training exercises
PS-8 is located along Taxiway No. 1 and 4, adjacent to Building 1019. During runway
soil compaction testing in July 1982, petroleum vapors were noted near Building 1019.
These petroleum vapors were attributed to leaks in the underground fuel lines that ran
under the area.
FT-1 is located south of the main runway and WW-a, between Taxiway No. 10 and theperimeter road and constructed of various separate areas.
-

A concrete block building with a surrounding of a roughly two feet thick and
300 feet in diameter raised gravel pad-

An unlined burn pit was built prior to 1970. Since 1970, a lined, circular burn
pit of gravel containing a mock aircraft has been utilized-

Oil/water separator possibly malfunctioned prematurely discharging an
oil/water mix

Wastewater Lagoons
WW-1 is located south of the eastern end of the runway, between the perimeter roadand the north-south portion of Taxiway No.10. This wastewater lagoon consists of two
interconnected lagoons with an approximate combined capacity of five million gallons.
-

Upper skimming lagoon: irregularly shaped with a length roughly 900 feet andvarying widths from 30 to 200 feet; a depth range of three to five feet-

Lower holding lagoon: approximately 450 feet long, 150 feet wide, and four
feet deep38

A concrete sluice provides a means for directing water from the upper lagoon to thesmaller lagoon. Together they drain into No Name Ditch with 360,000 to 580,000
gallons during dry seasons.
-

No Name Ditch: seemingly large flat surface area; flows perennially to thesoutheast within one mile crossing of Craig Road at an average rate of 0.75
cubic feet per second

This was also known to be utilized for disposal of storm and industrial wastewater;
known to have had JP-4 fuel, oil, industrial solvents, acids, and cleaning compounds
previously discharged. Even with around 50 oil/water separators and grit chambers
throughout Fairchild AFB, their improper servicing prior to May 1992 aides in theprobability that the installation housed the primary sources for WW-1 contamination.
SW-1 was used for disposal of all Base Wastes (i.e. industrial wastes, plating sludges,
solvents, lubricating oils, cutting oils and shavings, dry cleaning filters and spent
filtrates, paint wastes, coal fly ash, and miscellaneous sanitary wastes) from 1942 to
1957/1958.
Based on the four possible contamination sites identified in 1987, United States
Environmental Protection Agency (EPA) evaluated Fairchild AFB using the Hazard
Ranking System (HRS). Their scoring resulted in Fairchild AFB being added to the NPL
and an interagency agreement referred to as a Federal Facility Agreement (FFA) being
entered into by the USAF, EPA, and Ecology one year later in March 1989.
RI/ROD for Craig Road Landfill
The Craig Road Landfill (CRL) is located on property owned and operated by
U.S. Air Force as a noncontagious part of the Fairchild AFB installation. Its total area is39

approximately 100 acres, comprised of three inactive waste disposal areas, and islocated on the west side of Craig Road, roughly 0.7 miles south of Airway Height’s main
thoroughfare U.S. Route 2. This landfill was a former disposal location for Fairchild AFB,
used for general purpose landfilling. Municipal and industrial wastes were buried in twoof the three areas (Northwest Disposal Area (NDA) and the Southwest Disposal Area
(SDA)) and demolition debris from runway reconstruction was deposited on the groundsurface in the third disposal area.
NDA was active between the 1950s and 1960s. The process of landfilling was
primarily trench-and-fill, soil cover, and grading. This location is said to have hadmunicipal and industrial waste buried in trenches covering 6 acres. Investigation borings
showed a depth of fill material that exceeds 30 feet below the existing ground surface.
SDA was active from the late 1960s to the late 1970s. The process of landfilling
was primarily fill-and-cover in a topographical low area, possibly with some excavation.
The soil cover was graded and then overlain with concrete blocks and asphalt fromrunway reconstruction. It is said to have such waste disposed of in about 13 of its lowlying acres. Investigation borings showed a depth of fill material that exceeds 25 feetbelow the existing ground surface.
In the southeast disposal area, which covers around 20 acres, had various
construction and runway reconstruction debris deposited on its ground surface.
There were three primary environmental problems identified in the RI. First was thedetected concentrations exceeding federal maximum contaminant levels (MCLs) thatwere established under the Safe Drinking Water Act, of TCE, 1,1-Dichloroethylene (1,1DCE) with vinyl chloride in groundwater on-site and/or off-site monitoring wells samples,40and additionally detected in both nearby residential and municipal water supply wells.
Secondly were the sites NDA and SDA being identified as the sources of contaminationin question. Lastly, soil-gas measurements indicated volatile contaminants present in fillmaterial.
Investigation/Site Hazard Assessment and No Further Action at OW057
An Initial Investigation/Site Hazard Assessment (II/SHA) and No Further Action(NFA) at OW057 Performance Based Remediation Report was prepared by Bay West
Limited Liability Company (Bay West) for oil water separator (OWS) OW057 at Fairchild
AFB, Spokane, Washington. OWS sites on the installation are regulated under the Stateof Washington’s Model Toxics Control Act (MTCA). The Washington Department of
Ecology (Ecology or WDOE) serves as the lead regulatory agency. Historical datacollected at a particular site, referred to as OW057 in the September 2018 II/SHA
report, indicated that petroleum-related contamination may be present in soil andgroundwater. To further evaluate such findings and thus the potential threat to bothhuman and environmental health, additional sampling was carried out. Verification
testing for existence and delineation of the extent of petroleum contamination was
accomplished with further soil and groundwater samples. A major portion of theinvestigation consisted of field data collection over a year timespan, from February 1991
through January 1992.
Oversight of subsequent RI activities and agreement on final remedies selected
were presented in the ROD designated by the terms identified by the FFA, EPA, andEcology. The FFA established a procedural framework and schedule for developing,
implementing, and monitoring appropriate response actions conducted at Fairchild AFB.

41

The Safe Drinking Water Act (SDWA) amendments of 1996 implemented therequirement that once every five years EPA is to issue a new list of no more than 30
unregulated contaminants to be monitored by public water systems (PWSs). It was not
until reporting year 2020 that the first strands of PFAS related contaminants wereregistered on the Toxics Release Inventory (TRI). As of March 30, 2016, the EPA stated
330 non-Confidential Business Information (CBI) PFAS chemicals had been reported tothem and are listed in the public interim report. This does not include their reported 148
CBI PFAS substances (U.S. EPA, 2016).
The 2017 Contamination in Airway Heights, WA
Between the years 2013 and 2015, the EPA sampled and detected PFAS
chemicals in drinking water systems across the United States as part of a national
survey called the Unregulated Contaminant Monitoring Rule sampling event. Guidancefor Investigating and Remediating PFAS Contamination in Washington State provides abasis for future regulatory actions to protect public health intended for thoseinvestigating and cleaning up PFAS contamination within the state. Published on May 2,
2012, the third Unregulated Contaminant Monitoring Rule (UCMR 3) outlined therequired monitoring of 30 contaminants (28 chemicals and two viruses) between 2013
and 2015 using analytical methods developed by the EPA, consensus organizations orboth. Approximately 94 percent of Washington State’s residents that are served by its
132 public water systems saw monitoring (Gordon, 2022).
Monitoring included sampling for six PFAS compounds (Gordon, 2022):•

Perfluorooctane sulfonic acid (PFOS)•

Perfluorooctanoic acid (PFOA)•

Perfluorononanoic acid (PFNA)

42

•

Perfluorohexane sulfonic acid (PFHxS)•

Perfluoroheptanoic acid (PFHpA)•

Perfluorobutane sulfonic acid (PFBS)

Following this sampling event, several military bases in Washington state found theirdrinking water sources, both on- and off- base, tested for contaminates in response to a
directive from the U.S. Department of Defense (DOD) (Gordon, 2022; Vergun, 2020).
PFAS discovered at or around the following Washington state military
installations (Gordon, 2022):•

McChord Airfield and Fort Lewis (located between Olympia and Tacoma)•

Yakima Training Center (located near Yakima), which is part of JBLM•

Naval Air Station Whidbey Island (located near Oak Harbor)•

Naval Base Kitsap-Bangor (located near Poulsbo and Silverdale)•

Fairchild Air Force Base (located near Airway Heights and Spokane)

Fairchild AFB followed suit with that directive of the UASF to test water sources for
PFAS compounds PFOS and PFOA in April 2017. In May 2017, Fairchild Air Force
Base acknowledged its responsibility for widespread drinking water contamination
Airway Heights, to the northeast, leading the DOD to designate a testing zone and test
a sampling of residential wells (Villa & Breda, 2023; Landess, 2023). Water sampling ofover 369 drinking water wells of Airway Heights was conducted for non-organic
chemicals within the PFAS family in May 2017. 90 of these wells were found to have a
combination of PFOA and PFOS chemical strands that were over the EPA Health
Advisory of 70 parts per trillion (ppt). Initially 23 off-base wells adjacent to theinstallation’s eastern border were tested in April 2017. 30 additional water wells locatedto the south and east of Fairchild AFB were tested between May 8-10, 2017. Water
tested at three city wells in May 2017 found concentrations of PFOA and PFOS
between 1,400 – 1,500 ppt. Wells owned by the municipalities of Medical Lake and43

Airway Heights were also tested shortly thereafter (McCallum, 2020). Potentially togauge a contaminated distance range.
In September 2019, the Centers for Disease Control and Prevention (CDC) andthe Agency for Toxic Substances and Disease Registry (ATSDR) began an exposure
assessment (EA) with a public information meeting. Their research period concluded in
March 2022 with a similar meeting, to report their findings. Testing was conducted by
testing human blood of eligible Airway Heights residents. Individuals had to receive
drinking water from the City of Airway Heights Water Department and lived west of
Hayford Road for at least one year before June 8, 2017, be older than three years ofage, and not be anemic or have a bleeding disorder. Data was collected from 333
volunteers from 168 households, 286 adults and 47 children. Means of data collection
was a questionnaire, blood or blood and urine, and samples of tap water or tap waterand dust from homes. Results showed that on average, there were higher levels of five
PFAS compounds (PFHxS, PFOA, PFOS, PFNA and PFDA) in the sampled residents
than the average nationwide. Of the five compounds found in their testing, three of them
(PFHxS, PFOS, and PFOA) were the ones that contaminated the local water sources
over two years before. Given that such compounds are difficult to almost impossible tobreakdown, it is a possibility that these findings could be contributed to ingesting themwith drinking local water from years past; prior to the water shut-off in early 2017
(CDC/ATSDR, 2022). Additional and follow-up investigations are ongoing to determine
the degree and extent of PFAS contamination in drinking water wells both on- and offbase.

44

From small updates on well testing continuation to notices of public meetings
occurring, the local newspaper, The Spokesman Review, has been an informative
source of continuity since the notice of the 1993 contamination of JP-4 fuel. In the weekof public notification, the publication presented five articles between May 3 and May 17,
2017. Published on Friday, April 6, 2018, The Spokesman-Review newspaper put inprint a public notice from the Air Force a public opportunity to comment on the TimeCritical Removal Action (TRCA) for the Treatment of PFOS- and PFOA-Contaminate
Water in Residential Wells near Fairchild Air Force Base, Washington. They stressed intheir closing statement that this action does not include Airway Heights’ municipal watersupplies. The cause for the contamination was quickly contributed to historicaldispensed AFFF, the firefighter foam of choice for municipal fire departments, military
installations, and airports to fight liquid-fueled fires (i.e. hydrocarbons) (WSDE, 2021).
Hydrocarbons
Hydrocarbons are chemicals composed of carbon and hydrogen. They are fuels
non-miscible with water due to their non-affinity for water (BIOEX, n.d.). Gasoline,
naphtha, ether, benzene, kerosene, jet fuels, diesel oils and other liquids with highly
flammable vapors have the potential to reignite due to their vapors (Tuve & Jablonski,1966). Hydrocarbon chemicals contain only hydrogen and carbon atoms. Carbon atoms
in Polycyclic Aromatic Hydrocarbons (PAHs) form a ring around the hydrogen and attimes have additives like automotive gasoline, benzene, butadiene, fuel oils, and jet
fuels. Over 100 different substances that are formed during the incomplete burning ofcoal, oil and gas, garbage, or other organic substances like tobacco or charbroiled meat
are considered as PAHs. ATSDR states that PAHs are found in coal tar, crude oil,45

creosote, and roofing tar, but a few are used in medicines or to make dyes, plastics, andpesticides (CDC/ATSDR, 2008). Such fueled fires are categorized as being Class B
fires making the foams Class B foams. Class B fires are categorized as three separate
categories: light hydrocarbons (i.e. gasoline, heptane, cyclohexane, terpenes, etc.)
heavy hydrocarbons (i.e. diesel, kerosene, etc.), and aromatic hydrocarbons (i.e.
benzene, toluene, etc.) (BIOEX, n.d.), however AFFF suppresses well in either
category.
PFAS
There is no precisely clear definition of what constitutes a PFAS substance given
the inclusion of partially fluorinated substances, polymers, and ill-defined reaction
products. The term PFAS is relatively new, and it has only become part of the modern
lexicon within the last decade or so. In older references, the term perfluorinatedchemicals (PFC) was used. For either label, there is not a distinct definition which canlead to significantly affecting what is and what is not considered a PFAS. Additionally,
like other chemicals, many strands of PFAS are used in such a way that their use is atrade secret, or there has been no requirement to identify them (Williams et al., 2022;
Gaines, 2022). Specifically, PFOA was used as an aqueous dispersing agent to makefluoropolymers. Fluoropolymers impart valuable properties, including fire resistance andoil, stain, grease, and water repellency to articles. Though it is no longer used in the
United States to manufacture fluoropolymers, such items are still able to be imported as
parts to articles (U.S. EPA, 2015).
Years after mass production had commenced, internal communication occurred
within at least three manufacturing companies of consumer products over PFAS health46

concerns, 3M, DuPont, and Chemical Concentrates Corp. Said concerns were notconveyed to the public at the time (Appendix C). Documentation stating that any militarybranch had the same or similar knowledge was not located within the extent of thispaper’s research.
PFAS represent a growing, increasingly diverse inventory of chemicals of interest
to the public, scientific researchers, and regulatory agencies world-wide. Currently, thenumber of PFAS compounds listed on the EPA’s CompTox Chemicals Dashboard is
14,735 (U.S. EPA, 2022). As synthetic chemicals, many PFAS, including PFOS andPFOA, do not break down in the environment, can move through soils and contaminate
drinking water sources, like seen in Airway Heights, WA, and build up (bioaccumulate)in fish and wildlife. They generally consist of a carbon backbone with fluorines
saturating most carbons and at least one functional group, such as carboxylic acid,sulfuric acid, amine, or others. Starting in 1999, the Centers for Disease Control andPrevention sampled the blood of general U.S population’s for PFAS through the
National Health and Nutrition Examination Survey. Results of these tests have shownthat among other PFAS, PFOA, PFOS, and PFHxS have consistently been found in 99
percent of subjects sampled (Gaines, 2022). With the recent higher use of single-use
surgical masks, contamination of both humans and environment entities is a possibility,
but there is more possibility with tested fire fighter masks see Appendix C. There has
also been a recent category of illness contributed to Teflon and thus referred to as
Teflon-flu (Kindelan & Salzman, 2024).
Similarly to the oversight of creators and engineers of PFAS, those planning or
utilizing Fairchild AFB’s landfills did not seem to have the notion of ‘what would happen

47

to the environment over time’ was not in the forefront of thinking. Officials at Fairchild
AFB may not have been aware of potential future contamination from said chemicals
during the years that their on-site landfill and Craig Road Landfill were operating, it was
known of their use for all categories of disposal, to include hazardous waste.
Craig Road Landfill
Decomposing domestic and industrial waste containing PFAS and rainfall cancreate leachate that contains PFAS released from disposed products. Older un-lined
landfills can release leachate to groundwater (WSDE & WSDH, 2021). Even with its
lining, leeching could still be possible. Leachate produced in lined landfills is typicallytransferred to WWTPs for further treatment. During the April 1992 RI on CRL, theresults of the modeling effort indicated potential for leachate to develop from infiltrationof precipitation. However, possible reduction or elimination could occur by adding
barrier layers (i.e., landfill cap), revegetating the site, and providing runoff controls forthe landfill (WSDE & WSDH, 2021). .
“Landfills contain a variety of waste including inert materials (like wood or ash),disposed consumer products, and various organic wastes and solvents. Decomposing
waste and rainfall can create leachate that contains water, metallic ions, acids, andother contaminants including PFAS. Landfills manage these liquids differently, but they
can be a point of release of PFAS to the environment if leachate containing PFAS is notcollected in a lined system, or when leachate from lined landfills is sent to wastewater
treatment.” (WSDE & WSDH, 2021).
Military Fire-Fighting Training with AFFF

48

MIL-F-24385 is the U.S. NAVY’s publication for Military Specification Fire
Extinguishing Agent, Aqueous Film Forming Foam (AFFF) Liquid Concentrate, Six
Percent, for Fresh and Sea Water. This instruction was published on November 21,
1969, superseding the April 25,1967 version. Said specification covers the requirements
for AFFF liquid concentrate fire extinguishing agent consisting of fluorocarbon
surfactants and foam stabilizers. It describes how the liquid concentrate was diluted foruse in concentrations of six parts concentrate to ninety-four parts fresh or sea water byvolume. The solution of AFFF concentrate in water shall produce a foam possessing an
expansion of 7.0 minimum and a twenty-five percent drainage time of three minutes
minimum value when tested using fresh/tap water and synthetic sea water.
“The film produced shall be able to spread over the surface of the fuel resulting ina surface from which no sustained ignition of fuel vapors can be detected. Such foams
serve the fire extinguishing process in two ways: they block the feedback of radiantenergy to a fuel surface and prevent further release of flammable vapor after the flames
have been suppressed. Once sprayed, these foams release a thin surface film which
persists on the fuel-surface, and which has been found to be impervious to flammable
fuel vapors while quickly reforming whenever it becomes ruptured. The thin film is not
only capable of spreading over the fuel-foam interface, but also over fuel areas which
are not fully covered with foam.”In testing this solution’s fire performance, the following tests were to be accomplished.
Twenty-eight square-foot test – the fire shall be completely extinguished with anapplication density of 0,10 gal/sq ft (84 second application time) or less, and shallexhibit a 25 percent burn back time of 240 seconds

49

Four-hundred square-foot test – at least 85 percent of the fire shall be
extinguished within 30 seconds and the total of the “percent of fire extinguished” values
recorded at 10, 20, 30, and 40 seconds shall be 285 or greater
Twelve-hundred sixty square-foot test – at least 85 percent of the fire shall be
extinguished within 30 seconds and the total of the “percent of fire extinguished” values
recorded at 10, 20, 30, and 40 seconds shall be 285 or greater
Testing for quality assurance required five filled 5-gallon containers from the same
manufacturer lot and picked at random. Unless otherwise stated in the contract orpurchase order, the supplier is responsible for the performance of all inspection
requirements in accordance with this instruction. Except as otherwise specified in thecontract order and with the approval of the U.S. Government, the supplier may use his
own or any other facilities suitable for accomplishing these requirements. The
Government reserves the right to perform any of the inspections set forth in thisspecification where such inspections are deemed necessary to assure supplies andservices conform to prescribed requirements.
Regarding testing accomplished by military personnel, AFFF was used inabundance during training exercises at the fire-fighting training areas, not only on
Fairchild AFB. Firefighting training was conducted for the purpose of training fire fightersin utilizing AFFF, not testing the foam itself. It was not until September 2017 that theinclusion of testing for PFOA and PFOS in AFFF was seen in MIL-F-24385, yet sixteen
years prior, superficial environmental impact had been documented (Naval Sea
Systems Command (Ship Systems), 2017). Until 1991, fire training exercises are said tohave included 125 gallons of AFFF and held two to three times a month. On Fairchild50

AFB, proof of its extended use and allowance to drain away was noted in the 1992
ROD, “Fuel stains and dead vegetation was observed within the drainage areaadjacent to the discharge port.” Though the use of AFFF was halted in 2016 on
Fairchild AFB, there was still the concern of storing and thus disposing of alreadyproduced AFFF for the installation and consumers nation wide.
Aircraft Crashes of Airway Heights, WA
With fuel fires such as those that occur at aircraft crashes it leads to therealization that AFFF type of suppression is a requirement to quickly extinguish theirfires. Patent 3,258,423 describes the operation of its spray-gun in times like these withdry chemical powder and foaming solution. It has a dual nozzle arrangement designedwith pistol grips that have trigger type shut-off valves to permit an easy on-off operation
with one hand on each grip. Powder and foam are conveyed through discharge linesand discharged as a spray through separate nozzles. Each nozzle is mounted in a fixed
position relative to each other on a rod holder. The foam nozzle is equipped with adischarge tip. A tip option that is identified in the patent has a convex screen mounted
in the front to cause the foam to fan out in a wide arc upon discharge and was rated toproject 50 gallons per minute at 100 pounds per square inch (psi). Its solution can bemade into a foaming mass by mechanically mixing with air, other gases or conveniently
formed by adding a suitable amount of Freon liquid to the discharge line, converting thelatter into a vapor phase and thus forming a foaming mixture. The operator begins withthe dry chemical discharge initially and moves in a given direction. They then direct thefoam discharge over the area covered by the power until the entire area is blanketed
successively with dry chemical and with foam. The foam covers the area after the dry
chemical has extinguished the flames. 150 square feet of gasoline fire could be51

extinguished with about 20 lbs. of the dry chemical (KHCO3) powder and 5 gallons ofperfluorocarbon foam. The foam is preferably applied with a water density of 0.03 gal/sq ft.
A nozzle requires a pressurized system for discharging, a separate container fora dry chemical and a solution container which are good additions to mobile units to bereadily dispatched to the scene of hydrocarbon fires. Following completed crashinvestigations, it is required to dispose of the wreckage and the realization of expended
associated chemicals that includes JP-4 fuel to the wreckage site’s environment.
Fairchild AFB historically has had at least ten military aircraft crashes spanning fortythree years (1951-1994). One instance involved two aircrafts. The following
descriptions are of the five most recent crashes with highlighted details from the
documented incidents in the Bureau of Aircraft Accidents Archives, under the locationof Fairchild AFB and span from.

December 12, 1957: During a routine training mission, eyewitnesses state the B-52D
Stratofortress aircraft, No. 56-0597, left the runway leading into an abnormally steep
climb to an altitude of approximately 2,000 feet. Fire started coming from the jetengines and pieces of metal began flying off the engine cowlings and mounts. The
aircraft stalled, executed an abrupt, right wingover and appeared to level off. However,at an altitude of approximately 500 feet, the plane nose-dived and crashed in a
stubbled wheat field one mile west of the base. Exploding jet fuel sent a large columnof smoke into the sky, attracting scores of curious onlookers. It is believed the loss ofcontrol was the consequence of an incorrect wiring of stabilizer trim switch. One crew
member was injured while eight other occupants were killed.
52

September 8, 1958: Engaged in a local training flight at Spokane AFB, consisting ofvisual and instruments approaches and landings two Boeing B-52 Stratofortressaircrafts collided at 900 feet. The collision was the result of the approach procedures not
being followed by the crew. While approaching runway 23, at about three miles from thethreshold, aircraft one cancelled their instruments approach to continue operating on
visual mode. In the meantime, the second B-52 registered 56-0661 which was insecond position must switch from visual mode to instruments approach procedures. The
control tower didn’t pick up the more distant B-52 until it was about three miles from therunway, when the closer bomber was on its final approach. The tower ordered the firstplane to go up and to the right – a standard breakaway maneuver – while the closer one
should have followed procedures to go down and to the left, to land. Instead, bothplanes pulled up and to the right, and into each other. Investigations were unable todetermine the reason why the crew failed to follow the standard procedures and ATC
instructions. On board 56-0681, five crew members were killed while two others wereseriously injured. On board 56-0661, only one crew survived, all eight others have been
killed.

April 1, 1960: Just after liftoff, while climbing, the airplane went out of control andcrashed in a huge explosion less than 10 km from the airport. Eight crew members were
killed and one survived. The aircraft was destroyed. It is believed the loss of control wascaused by a structural failure of the upper wing surface.

53

March 13, 1987: A B-52 Stratofortress and a KC-135 Stratotanker took off from
Fairchild Air Force Base (AFB) to practice aerial maneuvers for a 15-minute air showscheduled on Sunday, May 17, Fairchild's annual Aerospace Day. The show was to be
the debut of a new aerobatics team dubbed the Thunderhawks, the brainchild of thecommander-in-chief of the Strategic Air Command (SAC). Its purpose was todemonstrate the capabilities of SAC’s large aircraft through a series of exciting routinesthat included a low-level refueling simulation, high bank turns, and flybys down the
runway.
The KC-135A-BN Stratotanker, No. 60-0361, had three instructor pilots aboard
the aircraft, but no one on the ground at Fairchild knew who was in command of theaircraft when it took off. Also, on board the airplane were two navigators and a refuelingboom operator.
The KC-135 had just taken off from runway 23, in tandem with the B-52,
executing a steep left-hand turn when it suddenly rolled from an intended 45-degreebank to almost 90 degrees, stalling the two engines on the left wing. The crew managed
to level the aircraft, but it was flying too low and slow to recover. The plane crashedlanded in an open area north of the flightline, behind three large hangars, narrowly
missing the base’s bombing and refueling squadron offices. It skidded through asecurity fence, across an access road, and killing a member of the Thunderhawks who
was sitting in their car watching the flight on their day-off from flying. The aircraft
traveled for another 200 yards, then hit an unmanned weather radar tower and burst
into flames. During the journey, the tail section separated from the fuselage as well as54the wings, engines, and wheels. One wing, ripped off by the collision with the radar
tower, landed 50 yards beyond the burning wreckage.
Within minutes, Fairchild’s crash teams were on scene, fighting the fire causedby spilled jet fuel. Spokane International Airport, four miles east of the base, dispatcheda crash truck and the Spokane Fire Department mobilized an entire engine company toassist in battling the blaze. Because of the toxic fumes and dangerous flare-ups,
reporters and photographers were not permitted near the scene. It took firefighters morethan three hours to extinguish the flames and hot spots from the crash.

June 24, 1994: Czar 52 and a KC-135 Stratotanker took off from Fairchild AFB topractice maneuvers for an air show scheduled for Sunday. Czar 52 was flying in tandemwith the KC-135, slowly circling the airfield and making flybys down the runway.
Occasionally, the bomber climbed steeply to 1,000 feet, then executed a“wingover” and descended, its eight jet engines dramatically trailing smoke. At 2:16
p.m., the pilot of the KC-135 finished practicing their air-show maneuvers and landed
his aircraft. Czar 52 continued flying down the runway at a low altitude and executed a
missed-approach or “go-around” maneuver. Approaching the runway’s end, the plane
climbed steeply and banked left into a tight 360-degree turn around the back of the air
traffic control tower. The aircraft started to level off at an altitude of about 250 feet, thensuddenly banked so steeply that the wings became vertical. Flying at approximately 170
miles per hour, Czar 52 narrowly missed a three-story brick building housing the Air
Force Survival School before stalling and plummeting to the ground. The tip of the left
wing clipped a set of power-transmission lines before hitting the ground, disrupting

55

electrical service to the base's air traffic control tower and several dozen homes near
Medical Lake. The bomber crashed in an area only 50 feet from the base’s undergroundnuclear weapons storage area, scattering wreckage over five acres. No one outside of
the aircraft was killed or injured.
An armed patrol was immediately dispatched to the crash site, just outside theirperimeter fence, to establish a security cordon. Within minutes, emergency crews andrescue teams were on scene to fight the fire. It took them nearly three hours to
extinguish the flames from the crash. Pockets of fire continued to erupt as oxygen
reached volatile hot spots in the rubble. Once the fire and rescue teams were finished,
the crash site was secured by Air Force Security Police to await the arrival of accident
investigators from other bases. On September 28, 1994, the Air Force Accident
Investigations Board released the results of its investigation which blamed the accident
on the pilot, who had been practicing unauthorized and unsafe maneuvers whichcaused the death of themselves and their three crewmembers.
Wildland Fires
Fire suppressant foams and retardants are key components in smothering
wildfires in Washington State and worldwide. Though a wildland fire could include Class
B fuels, records that would show data on PFAS chemicals in Washington state were not
located during the research of this paper. Such data would be wildfires, their locations,and means of fuel.
Agricultural Chemicals
Biosolid Fertilizer. Agricultural farming requires a plethora of means (seed, enrichedsolid, clean water for irrigation, proper sunlight, and fertilizer). Farmers are often

56

working with razor-thin profit margins so a selling point can often be cheap products
when inexpensive versions are not available to them (Teirstein, 2024). Biosolids, also
referred to as sludge or residuals, are a treated byproduct from wastewater plants to be
utilized as fertilizer or a cost-effective method of recycling waste that otherwise would
be disposed of at a landfill or an incinerator (Homsi, 2024). Some 19 billion pounds ofwastewater sludge was spread on farmland in 41 states between 2016 and 2022. The
EPA estimates that 60 percent of biosolids in the U.S. are applied to agricultural lands
and when done so properly, biosolids can be a nutrient addition, improve soil structure,
and a means for water reuse (US EPA, 2016b; Dyjak, 2022; Teirstein, 2024).
Biosolids produced in WWTPs where PFAS are present can in turn becontaminated with PFAS. It can be used as fertilizer for which, in nearly every state, isscreened for pathogens and heavy metals like lead, arsenic, and mercury. PFAS’ strong
molecular bonds aid in their withstanding conventional wastewater treatments. But moststates don’t currently test biosolids for PFAS, and state officials across the Midwest say
they’re in uncharted territory without the proper tools. PFAS in municipal and industrial
wastewater entering WWTPs may be partitioned into different media (i.e. solids andliquids) and transform into terminal PFAS compounds (WSDE & WSDH, 2021). If
wastewater plants detect two compounds, PFOA and PFOS, above 100 parts per billion(ppb) in biosolids, they are considered “industrially impacted” and can no longer beapplied to land. If they're under 20 pbb, they’re in the clear. Preliminary research oftested topsoil, surface water, and well water samples from farmlands has shown that
the PFAS in waste sludge is absorbed by crops and, in turn, consumed by livestock; it’seven been found in chicken eggs (Teirstein, 2024).

57

In February 2024, five farmers in Johnson County, Texas, sued Synagro, abiosolids management company based in Maryland, and its subsidiary in Texas.
Synagro has contracts with more than 1,000 municipal wastewater plants in North
America and handles millions of tons of waste every year. The company separates
liquids and solids and then treats the solids to remove some toxins and pathogens.
Synagro repurposes 80 percent of the waste it treats, some of which is marketed as
Synagro Granulite Fertilizer. The lawsuit claims Synagro “falsely markets” its fertilizers
as “safe and organic.” The plaintiffs accuse the company of selling fertilizer with highlevels of PFAS and failing to warn farmers about the dangers of PFAS exposure(Teirstein, 2024).
Contamination ranging from 91 to 6,290 ppt was reported in soil and water
samples from the plaintiffs’ properties. The county also tested tissue from two fish andtwo calves on those farms. The fish tested as high as 75,000 ppt. The liver of one of thecalves came back with an astounding 610,000 ppt of PFOS — about 152,000 times
higher than the EPA’s new PFAS drinking water limits (Teirstein, 2024).
Maine banned the use of biosolids as fertilizer in 2022 after dozens of farms
tested positive for forever chemicals. A farmer in Michigan who used biosolids fertilizer
was forced to shut down his 300-acre farm after state officials found PFAS on theirproperty. With the continued use, banning biosolids may not be a popular policy solution
among most states (Homsi, 2024). There’s still a limited body of research on how PFAS
are transferred from biosolids and soil into crops, agricultural products, and the foodsystem. The EPA’s new PFAS rules don’t apply to biosolids, which means thiscontamination will continue until regulations are in place. The EPA said it aims to58

conduct a first-ever assessment of PFAS in biosolids later this year, which may result in
new restrictions. Toxicity, concentration, and pathway of exposure determine the risks
that PFAS in biosolids pose to human health and the environment. Fundamental PFAS
concentration data to characterize Washington biosolids is documented to be lacking.
Further evaluation is outlined in the Department of Ecology for the State of Washington
and Wahington State Department of Health’s revised September 2022 Per- andPolyfluoroalkyl Substance Chemical Action Plan (WSDE & WSDH, 2021).
Local to Fairchild AFB, food items potentially contaminated with PFOA andPFOS were identified in May 2017 at the Airway Heights Corrections Center’s
Correctional Industries’ food production facility. Food produced at the facility are for
distribution for consumption by inmates, not sold to commercial venders. There was noconcrete data or testing of the ingredients provided in the memorandum distributed by
Fairchild AFB’s Public Affairs Office on May 17, 2017. The recall was a voluntary
precaution taken by the Washington Department of Corrections regarding the PFAS
water contamination in Airway Heights (FDA Office of Regulatory Affairs, 2017).
Pesticides and their Packaging. Because PFAS act as surfactants — chemicals that
help disperse components in liquids — PFAS can be useful ingredients in chemical
formulations like pesticides to ensure that they spray evenly. The EPA has banned 12
common PFAS as additives in pesticides, but others may still be included informulations that have yet been identified or disclosed (US EPA, 2021). Because PFAS
are listed as inert (rather than active) ingredients, they don’t have to be disclosed on
ingredient lists, making it hard to know when and where they are present. Additional
PFAS can also leach in when pesticides are stored in plastic containers that have been59

fluorinated or treated with fluorine to make them more resistant to degradation — which
generates unintentional PFAS in the process. An estimated 20 to 30 percent ofpesticide containers use fluorinated plastic, making leaching a serious concern evenwhen PFAS have not been added to the pesticides themselves (US EPA, 2021).
Conclusion
With nearly 15,000 chemical compounds that are associated with various
cancers, decreased immune response, liver disease, and reproductive ordevelopmental issues, among other adverse health outcomes, it is no surprise thatstrands of PFAS are found in at least 25 industries with a plethora of applications
worldwide. Residents of Airway Heights, WA who tested positive for PFAS were tested
via blood and/or urine samples. There is no reason that they not could have ingested
the compounds from not only their water, but also from the air, dust, food grown within
the study area, and/or with an abundant use of identified consumer products like
Scotchguard, cleaning solutions, furniture surface sealants, textile fire retardants ofolder furniture, or even exposure at their workplace. Fairchild AFB has had two landfills
both having been closed due to consistent disposal of hazmat waste lacking inprotective measures causing contamination at the location sites. These locations arestill standing. AFFF has a high probability of being a partner source to the possible
leeching of hazmat waste. After dispensed, the fire-fighting foam is left to dissolve
without a way to be filtered from nature (i.e. soil, sand, water, etc.).
The Pacific Northwest is also prone to wildland fires leading to a wide use of fire
retardants. Though there were no Class B fires utilizing AFFF located in digital records,
the research did provide insight into how fire retardants affect the environment. They60

have parallel results in suffocating both vegetation and wildlife. With that said, whoshould blame be placed? Should it in fact have been the United States military,
Fairchild Air Force Base itself, health regulation organizations, the companies like Du
Pont and 3M that created and widely utilized PFAS compounds, or perhaps it should be
the companies that created the requirement of said products because of theirinventions utilizing hydrocarbons requiring an invention to counteract such fueled
flames? In the interest of this research project, seemingly PFAS compounds being
included in the varied list of industries because of properties that they possess seems
shortsighted when PFAS compounds also hold the means to the end of life. It also
stands to reason that humans run companies, so should humanity be held accountablefor homicide if people die from an illness caused by PFAS? Though the majority of theaircraft crashes of the study area occurred prior to the inclusion of AFFF in
extinguishing such fires, some similar substance had to be utilized. The use of AFFF on
the later crashes, however, lacked in being identified on TRI records located during thisproject’s research phase.
Blame cannot fix what was broken, the fortitude of creating organizations –including the U.S. government, scientists, etc. to seek future consequences to bothconsumers and the environment. Ultimately, much like research into plastics and theirmicroplastics, once created, there is no filter that can correct the flaws of per- and polyfluoroalkyl substances. People in charge of companies must want to change, seek
knowledge before committing to doing so, accept the outcomes of inventions even if
they do not work in one’s favor, and allow positive change to overpower ease andcomfort of short-term success.

61

There have been a lot of missed steps in the process of environmental protection
stretching across the United States and the globe. Quick recognition by the DOD was
not a means to accept blame under the guise of bringing recognition of their part in theclean-up efforts. Though they were in fact working quickly to counteract theunprecedented PFAS contamination of Airway Heights in hopes to limit use ofcontaminated water and work with local agencies to remove possible future
occurrences, the DOD saw the problem they had a hand in by bringing forth a reason
for PFAS and thus AFFF and knew that they needed to stand for cleaner means andwater so that the companies that have led them astray would hopefully follow suite.

62

APPENDIX A

63

APPENDIX A

64

65

66

67

68

APPENDIX B

69

APPENDIX B
Hazardous Geology
Types of Hazardous Geology are Earthquakes, Rockfall, Landslides, Debris Flow,
Water and Ice, Natural Pollution, Anthropogenic Pollution, Seismic hazards related toearthquakes (i.e ground rupture/faulting, liquefaction, strong motion, and tsunamis), andMineral Hazards (i.e. asbestos, radon, and mercury). Geologic formations identified by
Washington State Department of Natural Resources and adopted into the Spokane
County Critical Area Ordinance as having a high susceptibility for landslides.
•

Alluvium-Qa (Quaternary) is sorted combinations of silt, sand, and gravel
deposited in streambeds and alluvial fans; clasts are generally rounded andderived from local bedrock sources or reworked Puget Lowland glacial deposits.

•

Alluvium-Qal (Holocene) is clay, silt, sand (mostly quartz), gravel, and organic
matter.

•Landslide Deposits-Qls (Holocene) is poorly sorted mixtures of locally derived
earth materials emplaced by mass-wasting processes.

•

Landslide Deposits-Qmw (Holocene and Pleistocene) Mass-wastage deposits—Colluvium or landslide debris with indistinct morphology, mapped where
sufficiently continuous and thick to obscure underlying material. Unit isgradational with units Qa and Ql.

•

Latah Formation-Tc (Pliocene) is massive and dense caliche with some sandand gravel.

•

Latah Formation-TI (Eocene) is sandstone and clay. Abundant marine fossils
and common limestone concretions.

The origin of the Hazardous Geology data is from USGS at 1:24,000 scale for theurban area of the City of Spokane and Spokane County and 1:100,000 for the ruralarea. The USGS utilized this data as only a flag and not a substitute for a field70verification by a qualified landslide or erosion specialist. In pairing this information in
conjunction to cities, towns, bodies of water, and parks these flagged hazards can beseen overlapping each type of the county's communal area. Spokane County Fire
Districts aide in showing the vast difference in area of responsibility and size of major
cities that first responders have.

* Geologic hazards extracted from State DNR maps, Published on December 6, 2022 by The City of Spokane* United States Geological Survey (USGS)* Map produced by Dana Rowland in ArcGIS Pro, 2023

71

72

APPENDIX C73

APPENDIX C.1

74

75

APPENDIX C.2

76

77

APPENDIX C.3

78

79

APPENDIX C.4

80

APPENDIX D

81

APPENDIX D.1
PFCIn April 2003, the Environmental Working Group (EWG) informed readers of
already proven products that included PFAS in either their construction or in theirchemical makeup. They stated that in the past five years (since 1998), the multi-billiondollar PFC industry, which underpins such world-famous brands as Teflon, Stainmaster,
Scotchgard, and Gore-Tex, has emerged as a regulatory priority for scientists andofficials at the EPA. Since the late 1990s, findings have elevated PFCs to the rogues
gallery of highly toxic, extraordinarily persistent chemicals that pervasively contaminate
human blood and wildlife. The PFC family is characterized by chains of carbon atoms ofvarying lengths, to which fluorine atoms are strongly bonded, yielding essentiallyindestructible chemicals that until recently were thought to be biologically inert (PFCs:
Global Contaminants | Environmental Working Group, 2003).

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APPENDIX D.2
TeflonIn 1946, DuPont introduced nonstick cookware coated with Teflon. A class-action
lawsuit uncovered evidence DuPont knew PFAS was hazardous and had contaminatedtap water but didn’t tell its workers, local communities, or environmental officials. This
information was not news to the E.I. Du Pont De Nemours & Company as they had
known of at least health effects stemming from Teflon since before 1970. In a released
document, ‘Request for Toxicological Information “Teflon” Division Chemicals, labeled“Company Confidential”, an employee of the Fluorocarbons Division of Washington
Works - a plastics factory in West Virginia owned by Du Pont at the time - wrote to the
Plastics Department of the Experimental Department at Du Pont on February 18, 1970,
speaking to past studies’ results and concern for employee’s wellbeing. They said,“Past studies made at Haskell Laboratory have indicated that ammonium
perfluorooctonate (C-8 APFC), which is used in the preparation of ‘Teflon’ dispersions,is highly toxic when inhaled and moderately toxic when ingested. However, data is notavailable on the chronic local or chronic systematic effect of the compound in the solidstate or dissolved in ‘Teflon’ dispersions.”
In closing, they requested means for personnel protection. “The plant medicalgroup is aware of the potential effects of the area chemicals and monitor area
employees, both individually and statistically. We are interested in determining thesystematic effect of repetitious skin contacts of short duration with C-8 APFC powder
and with the aqueous dispersion of polytetrafluoroethylene containing C-8 (chlorendic

83acid). …In addition to knowing these effects, we would like guidance on the personnel
equipment necessary for adequate protection against the effects.”

84Appendix D.3
Face Masks
Another item that hits close to home is the use in an abundance are brands offace masks. Researchers at Oregon State University tested face masks utilized forvarious tasks. The researchers used mass spectrometry to measure nonvolatile andvolatile PFAS in nine types of face masks: one surgical, one N95, six reusable cloth,
and a heat-resistant fabric mask advertised to firefighters. According to the calculations,
regular wear of the surgical, N95, and cloth masks would not pose a risk. However, thehigher PFAS levels in the firefighter mask exceeded the dose considered safe, but only
when worn for a full day (10 hours) during a high activity that boosted the wearer’s
respiration. Additionally, they estimated that even if everyone in the U.S. over age 5threw away one mask per day (90 billion marks per year), masks would be only a minor
source of PFAS in landfill leachates and domestic water. Unfortunately, other fabricatedsources have proven to be chronic pollutants to the environment and potentially thehealth of society (Muensterman et al., 2022).

85

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